POST COVID-19 CRISIS - IMPACT & SUGGESTIONS FOR BUSINESS IMPROVISATION
CMA Rajendra Rathi
Wishing a very good health to all. Currently we all are passing
through a very critical time which presently requires
us to stay at home and follow
the Government Guidelines to prevent ourselves
and avoid spread of CORONA VIRUS in the Society.
This is a worldwide pandemic and all the countries entered in to an
unprecedented crisis. India is looking towards safety of citizen as the first
priority followed by economic safety of the future. It is hoped that post
Covid-19 crisis, INDIA will bounce back with strong business platform and
become as the Best investment place for foreign investors too with a boost to
the growth engine of the world.
While safe-guarding the life of citizens through Lock-down the
Government has also initiated some of GST relaxations in regard to payment of
tax, filing of Returns etc. with a view to recover the health of the business.
v Few important recent GST amendment can be understood in line with the above.
Notification
No. 30/2020 – Central Tax dated 03.04.2020 has been issued relaxing the time
limit up to 30.06.2020 for opting Composition Scheme in the year 2020-21
Notification
No. 31/2020 – Central Tax dated 03.04.2020 has been issued lowering the rate of
interest for delay in filing GSTR-3B Returns.
Notification
No.32/2020 – Central Tax dated 03.04.2020 waives the late fee for the delay in
filing GSTR-3B Returns of March & April, 2020 up to 30.06.2020.
Notification
No.33/2020 – Central Tax dated 03.04.2020 waives the late fee for the delay in
filing GSTR-1 Returns of March & April, 2020 up to 30.06.2020
Notification No.34/2020 – Central Tax dated 03.04.2020 relaxes Composition Dealer Quarterly
Return GST-CMP-08 ending March, 2020 up to 07.07.2020 : Also GSTR-4 Return for
the F/Y 2019-20 up to 30.06.2020.
Notification No.35/2020 – Central Tax dated 03.04.2020 relaxes
various due date compliance to be made between 20.03.2020 and 29.06.2020 up to
30.06.2020.
Section 16(2) falls under Chapter V of CGST Act.
Exception carved out in the notification does not cover chapter V -
only chapter IV pertaining to time of supply is in exclusion. It looks the Government
purposefully not disturbed this time of supply as
it may lead to complexity in deciding supply and its taxability.
Hence, as per my understanding, this extension is applicable to
16(2) compliance as well. Accordingly 180 days coming between specified periods
will extend to 30th June 2020. Refer attached clarification dated 13.04.2020
also support our views.
While
making the payment to recipient, amount equivalent to one per cent was
deducted as per the provisions of section 51 of Central Goods and Services
Tax Act, 2017 i. e. Tax Deducted at
Source (TDS). Whether the date of deposit of such payment has also
been extended vide notification N. 35/2020-Central
Tax dated 03.04.2020?
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As per notification No. 35/2020-Central Tax dated 03.04.2020, where the timeline
for any compliance required as per sub-section
(3) of section 39 and
section 51 of the Central Goods and Services Tax Act, 2017 falls during the
period from 20.03.2020 to 29.06.2020, the same has been extended till
30.06.2020. Accordingly, the due date for furnishing of return in FORM GSTR-7 along with deposit of tax
deducted for the said period has also been extended till 30.06.2020 and no
interest under section 50 shall be leviable if tax deducted is deposited by 30.06.2020.
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Further
matching clause also relaxed so CMA can advise all their clients to file
refund on inverted duty structure immediately using online facility so same
will be received immediately to them
which will help them
to improve their
cash flow during
this tough time.
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Now we CMA can utilize this time to make possible value additions by
giving business improvisation /optimization suggestions through our institute
to Governmment as well as to Business, so as to socio economic growth can be
maintained with healthy life.
This can be achieved by three level actions plan.
v Suggestion at Govt. level.
Govt. can plan to bring following policies
as a measure of job safety and ease of doing business and an initiative in Digital
India environment:
(a)
Direct all the Businesses not
to lay off or remove the employees.
(b)
Support Businesses in a
possible manner as demonstrated by the Government in paying Provident Fund for
the period March, 2020 to May, 2020/
(c)
Rural socio-economic zone can
be developed in each district at village level/rural area level Especially for
labor-oriented industries in nearby area where labours are available
(d) Skill development center’s with IT facilities providing certificate
can be started at each town level as post COVID-19
requirement of skill
labor will increase
and job opportunities can be improved to skilled
man power.
(e)
All Govt. schemes can be
monitored by Robust system reports.
(f)
New education policy covering
health care, yoga and online/digital model at affordable cost making cost audit
and cost record mandatory in education services.
v Suggestion at Institute level
CMA Institute
can plan to help nation in achieving 5 trillion-dollar economy.
CMA
institute can develop format for optimization of business model for various
sector like:
·
Educate public to spend only for necessary livelihood
and to avoid luxury needs. To this a
matrix to be drawn Dos
and Don’ts for the next one year.
·
To conduct Seminars/Conference
only through video conferencing for the next one year
·
Automobile industry can think
about leasing model
·
Airline can convert passenger
plane into Cargo Plane for 6 months.
·
Textile can produce Apron for
health care institutions
·
Education system with online facility
·
Yoga and alternative therapy
facilities for mass at optimum cost with organic food
·
Labor can get become skilled by
having basis awareness about computer
CMA institute can publish back ground material on major sector like
infrastructure, automobile, health care, education, Banking, Agriculture as
well as on GST, Digital India, and import export.
v Suggestion at Members level.
(a) All CMA members to acquire proficiency in cost effectiveness model
for business to improve their efficiency and
profit.
(b)
New innovative, business to
business (B2B) platform can be developed for multipurpose solutions like
procurement and logistic optimization.
(c) Robust Audit tool for GST audit to make client 100% complied
(d)
Standard operating procedures
(SOP) to be developed for all major activities like GST Audit, Internal Audit etc.
Now we CMA have a challenge to prove ourselves as doctor for economy
booster in present crisis. We can contribute as Digital CMA in improving ease of doing business with optimization
of men, machine, money and health following social distancing till the time the
pandemic is completely eradicated.
Hope under inspiring leadership of president our institute will
create situational leaders at all over India in practice as well as in industry
to feel our profession presence to all stakeholder including rural area. Jai
CMA
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